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Inspection report: Department of Home Affairs, Australian Border Force, ADV Ocean Protector (R21/06970)

Inspection report details
Licence holder: Department of Home Affairs, Australian Border Force
Location inspected: ADV Ocean Protector
Licence number:  S0092
Date of inspection: 28 June 2021
Report number:  R21/06970

This e-inspection was conducted as part of ARPANSA’s baseline inspection program and was conducted using documents, photographs, and records sent by the licence holder, and with further clarification via phone or email as necessary. 

The purpose of the inspection was to assess compliance with the Australian Radiation Protection and Nuclear Safety Act 1998 (the Act), the Australian Radiation Protection and Nuclear Safety Regulations 1999 (the Regulations), and conditions of Source Licence S0092. 

The scope of the inspection included an assessment of the performance of the Department of Home Affairs-Australian Border Force (DHA-ABF) controlled Australian Defence Vessel (ADV) Ocean Protector, against the Source Performance Objectives and Criteria.  

Background

DHA-ABF is authorised under section 33 of the Act to deal with mobile or portable medical X-ray apparatus on the ADV Ocean Protector. The ADV Ocean Protector is a defence owned military patrol vessel operated by a civilian shipping company, assigned to the DHA-ABF Maritime Logistics Section for the conduct of maritime border operations in Australian waters. 

Aspen Medical provides on-board medical support under contract to DHA-ABF.  All radiography procedures and work instructions are authorised and controlled by trained and appropriately licensed Aspen Medical staff. Aspen Medical staff may deploy with the vessel on request of DHA-ABF depending on the profile of the vessel’s mission, however, the preferred option for the provision of any radiology procedure is for services to be conducted on-shore. 

The main codes and standards applicable to this apparatus are those that appear in section 59 of the Regulations and Radiation Protection Series C-5: Code for Radiation Protection in Medical Exposure (2019).

Observations

In general, the information provided for the e-inspection shows the management and any ‘potential’ operation of the controlled apparatus on board the ADV Ocean Protector to be satisfactory. Of note, Aspen Medical provided a declaration in the suite of documents stating “… that to date, there has been nil requirement for this equipment to be used on a patient” on board the ADV Ocean Protector. 

DHA-ABF’s current Radiation Safety Plan (RSP) showed no clear link identifying the relationship between DHA-ABF and Aspen Medical and the use of Aspen Medical’s own plans and standard operating procedures (SOPs) on board the vessel. 

Performance Reporting Verification

DHA-ABF’s quarterly reports have been submitted to ARPANSA in a timely manner in recent years and contained relevant information, including details of compliance with the Act and Regulations. Aspen Medical forwards any reportable information involving the controlled apparatus to the DHA-ABF Radiation Safety Officer (RSO) when required for DHA-ABF reporting. There have been no recorded issues reported for this controlled apparatus.

Configuration Management

Aspen Medical provided a comprehensive suite of documents and photographic evidence for the inspection including their mobile X-ray system safe work instructions and several SOPs incorporating, equipment serviceability, imaging guidelines and X-ray processing.

Photographic evidence showed that the unit is appropriately restrained within the ship’s hospital to prevent movement at sea. The unit is only used when requested by DHA-ABF and operated by qualified ASPEN medical staff.  

DHA-ABF provided an updated draft of the RSP, which now reflects the Maritime Section’s control over Aspen Medical’s relationship and its contractual arrangement with DHA-ABF.  

Inspection, Testing and Maintenance

DHA-ABF’s records indicate that the medical X-ray unit on board the ADV Ocean Protector has had maintenance conducted as sourced by Aspen Medical under the authority of DHA-ABF’s Marine Logistics & Aviation section. 

An appropriately licensed service technician undertakes compliance inspection, recertification and maintenance of the X-ray equipment. The most recent Certificate of Compliance was issued under the Western Australia – Radiation Safety Act following the unit’s service of 20 May 2021.  

Training

Under the current contract between DHA-ABF and Aspen Medical, no medical practitioner or paramedic is authorised or qualified to use the X-ray apparatus. A qualified radiographer will be engaged on an ‘as needs basis’ and when required, Aspen Medical will identify a qualified radiographer from their pool of licensed personnel. Under current contractual arrangements, evidence of training and certification is requested at the time of engagement to DHA-ABF. 

Event Protection and Emergency Preparedness and Response

The emergency procedures cover all operational aspects of the ship’s company including staff and equipment of the ship’s hospital. Any medical incident on-board is to be reported through to the ship’s master and DHA-ABF command team. Any radiation issue will also be reported through to Aspen Medical and again through to the DHA-ABF RSO.

Doors to the ship’s hospital are watertight and secured when the vessel is underway to prevent water ingress.  

Radiation Protection

Photographic evidence provided shows appropriate signage on doors with documentation indicating that the walls of the ship’s hospital are appropriately shielded.  

If the X-ray unit is to be used, Aspen Medical’s procedures require that:

  • appropriate personal protective equipment and Thermoluminescent dosimetry badges are worn,
  • the unit is operated from behind lead shielding, and 
  • the operator ensures that the patient is appropriately protected i.e. lead gowns and specific anatomical shields are used. 

Aspen Medical has engaged a qualified radiation physicist approved by the Western Australia Radiological Council to provide specialist advice on optimisation, dosimetry and oversee certification. 

Photographs could not be provided of the unit in operation due to this being an e-inspection and that, to date, there has been no requirement for X-ray procedures to be undertaken at sea.  

Security

The ship’s hospital doors are locked at all times when the ship’s clinician is not in attendance. Keys are stored in a restricted access safe available to the ship’s master and clinician.

Findings

The licence holder was found to be in compliance with the requirements of the Act, the Regulations, and licence conditions. 

The inspection revealed the following areas for improvement:

  1. Current Radiation Safety Plan does not reflect the contractual relationship and requirements with Aspen Medical. 

It is expected that improvement actions will be taken in a timely manner.